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CORRESP

 Troutman Pepper Locke LLP

 111 South Wacker
Drive

 Suite 4100

 Chicago, IL 60606

 April 14, 2025

 United
States Securities and Exchange Commission

 Division of Investment Management

100 F Street NE

 Washington, D.C. 20549

Attn: Ashley Vroman-Lee

Re:
 ABL Longevity Growth and Income Fund

Amendment No. 11 to Registration Statement on Form N-2

Filed March 4, 2025

Securities Act File No. 333-274405

Investment Company Act File No. 811-23900

Dear Ashley Vroman-Lee:

On behalf of our client, ABL Longevity Growth and Income Fund (the “Fund”), we are writing to submit the Fund’s
(a) responses to certain oral and written comments provided by the accounting division of the staff of the Division of Investment Management (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on
March 28, 2025 and April 8, 2025, with respect to the above-referenced Amendment No. 11 to the Registration Statement on Form N-2 and Statement of Additional Information (the “Registration
Statement”) and (b) the responses submitted in our letters to the Staff dated March 4, 2025 (the “Comment Response Letter(s)”).

Concurrently with the submission of this letter, the Fund is publicly filing Amendment No. 12 to the Registration Statement (the
“Revised Registration Statement”). Capitalized terms used but not otherwise defined herein shall have the meanings ascribed thereto in the Revised Registration Statement. For the convenience of the Staff, we have reproduced the
Staff’s comments below in bold and follow each comment with the Fund’s responses thereto.

I.
 SEC Accounting Comments Received March 28, 2025 to
N-2 Registration Statement

1.
 Prior to the Table of Contents, the Fund discloses that it may own certain wholly-owned subsidiaries. Please
confirm that the Fund will consolidate the wholly-owned subsidiaries and that all costs associated with the wholly-owned subsidiaries are included in the Fee Table, if any are expected to be formed within the first year of the Fund’s formation.

 The Fund confirms that the assets and liabilities of any wholly-owned subsidiaries will be consolidated with those
of the Fund and that the costs, if any, associated with formation and maintenance of wholly-owned subsidiaries are included in Item 8 of the Fee Table; we note that the Fund does not currently anticipate forming any wholly-owned subsidiaries within
the first year of operations.

 April 11, 2025

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 2

2.
 Page 3 of the Registration Statement includes the statement “The Manager believes that life expectancy
is one of the most important factors. . . however, consistent with industry practice, the Manager expects to use a single life expectancy provider as its primary life expectancy provider.” Please remove “consistent with industry
practice.”

 Please see page 3 of the Revised Registration Statement, where “consistent with industry
practice” has been deleted.

II.
 SEC Legal Comments Received April 8, 2025 to the March 4, 2025
Response Letter

3.
 Please confirm that the investment in assets with voting rights, such as Mortality Contracts issued by
mutual or fraternal issuers, which have nominal voting rights, would not exceed 10% of the issuer’s outstanding voting securities.

The Fund confirms that it will at no time hold more than 10% of the outstanding voting securities of an issuer. To the extent that it acquires
securities that have voting rights, such as variable Mortality Contracts issued by a mutual or fraternal insurance company, such contracts will represent a de minimus portion of the total policies (and as such the total membership voting
rights) of such insurance company. As a part of its overall risk management function, the Manager will monitor to ensure that the Fund does not have exposure to any issuer in excess of 10% of the total voting securities of such issuer.

4.
 The Fund states that no Mortality Contract will be registered for resale under the Federal Securities Law.
Staff notes that the disclosure on the Cover Page states that “when a Mortality Contract matures or is sold, the Fund intends to distribute the proceeds to its shareholders.” Please supplementally explain whether registration for resale is
not required in connection with the sales disclosed in the N-2.

 The Fund
confirms that it does not expect, and will not be required, to register for resale any Mortality Contracts in connection with the sales of Mortality Contracts referenced in the N-2. Any Mortality Contracts
that are securities will be sold pursuant to exemptions from registration, primarily utilizing exemptions available for private placements. We note that tertiary sales of Mortality Contracts are usually effected in a marketplace with sophisticated
and experienced Mortality Contract investors pursuant to Rule 506 under the Securities Act of 1933, as amended.

5.
 The Response states that “the Fund may invest in certain structured finance products, which are
securities”. Then it states “structured finance products are privately constructed pools of assets that generally are not registered securities.” The Fund then states that “the Fund does not expect that any structured finance
products in which it invests would be registered [as securities] under the ’33 Act or ’34 Act.” This is potentially confusing. Please tell us the intent of the Fund with respect to investing in structure finance products and also add
a brief description of the structured finance products in the discussion of the Investment Strategy section and not only in the risk factors section. Please also supplementally explain generally who the counterparties are for such structured finance
products, whether the Fund has already identified such counterparties, and how the associated fees and expenses of these products might impact performance.

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 April 11, 2025

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 3

 While some structured finance products themselves can be securities, the underlying assets,
such as Longevity Assets, held by such structured finance products are generally not expected to be securities.

 The Fund further expects
that, by and large, structured finance products in which it invests will offer their interests through private placements such as described in Section 4(a)(2) of the Securities Act or in the form of collateralized structured notes.

The intent of the Fund to also invest in structured finance products, as described above, rather than directly investing in the underlying
assets is to have the flexibility to manage risk and gain access to pools of Longevity Assets that it otherwise could not access directly.

III.
 SEC Chief Counsel Office and Chief Accounting Office Received April 8, 2025 to the
March 4, 2025 Response Letter

6.
 Please either confirm that CFCs will not be counted as investment securities for purpose of determining the
Fund’s status as an investment company under Section 3(a)(1) of the 1940 Act or explain why the CFCs should count as an investment security under Section 3(a)(2) of the 1940 Act.

We confirm that the Fund’s interests in a CFC, if any, will not be included as “investment securities” (as defined in
Section 3(a)(2) of the 1940 Act) for purposes of determining the Fund’s status as an investment company under Section 3(a)(1) of the 1940 Act. The Fund expects that it will hold in excess of forty percent (40%) of its assets
in investment securities without counting interests in a CFC, if any.

7.
 In calculating the Management Fee, please disclose that the Fund will use a market quotation first, but if
not readily available, then the Fund will use fair value, if accurate.

 The Fund confirms that for purposes of
calculating the Management Fee, the Fund will first seek to use a market quotation to the extent available. Only if a market quotation is not available will the Fund utilize the fair value determination disclosed. The Fund has provided this
disclosure on page 7 of the Revised Registration Statement accordingly.

8.
 Please supplementally tell us what Lapetus’s incentive to provide whatever values the manager wants in
order to keep the manager’s business. Corp. Fin. Release IC-34128 from January 6, 2021 – it says “we believe that the conflict is not one from a particular investment adviser, but that a
pricing service would provide higher estimates to retain business.”

 There are several key reasons why the
Manager does not have an incentive to influence Lapetus’ valuations of Mortality Contracts.

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 April 11, 2025

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 4

 First, Lapetus is set to charge the Manager a fixed, market-level rate per Mortality
Contract. Thus Lapetus does not have an economic incentive to produce results that are any different whether a life expectancy is commissioned by the Manager or another client. Moreover, frequently multiple market participants commission life
expectancies from Lapetus on the same Mortality Contracts and the same time (e.g. one for a buyer and one for a seller). If Lapetus were to furnish diverging reports to different parties, such an unsavory business practice would be quickly
uncovered.

 Second, the Manager’s compensation based upon valuation of Mortality Contracts is capped at the lesser of (i) the
purchase price plus premium paid thereon or (ii) any write-down below the amount set forth in section (i). Therefore, an artificially reduced or increased life expectancy report (which would when added to other factors to determine the value of
a Mortality Contract) would add little to no value to the Manager’s compensation. Moreover, life expectancy while highly valuable, is only one of the factors used to determine the value of a Mortality Contract. As a result, the Manager is not
incentivized to seek artificially reduced or increased life expectancies on its insureds to increase its management fee, since the Manager will not earn increased management fees as a result.

Third, the Manager relies on the same Lapetus life expectancy estimates as part of its overall evaluation to determine whether to buy, sell, or
hold a Mortality contract. Lapetus is not aware of the Manager’s proposed use of the life expectancy information. For this reason, an inaccurate life expectancy report would frustrate the Manager’s ability to properly trade its assets.
Therefore, the Manager requires the most accurate life expectancy estimates to assist the Manager’s evaluation of the value of the Mortality Contract.

9.
 In Comment 13(2), at the end of the first paragraph under (ii) – the Fund states that using multiple
different LE providers would result in reduced accuracy:—Please confirm to us that the result of the fair value process, including the LE inputs is to obtain “the price that would be received to sell the assets. . . in an orderly
transaction between market participants at the measurement date” within the meaning of ASC 820 and that using the single LE provider Lapetus serves that goal and is not expected to result in assets being valued at a price greater than what
could be obtained in an orderly transaction between market participants at the measurement date.

 The Fund confirms
that the goal of the fair value process, including application of the life expectancy estimate from a single life expectancy provider (i.e. Lapetus) is to obtain “the price that would be received to sell the assets. . . in an orderly
transaction between market participants at the measurement date” within the meaning of ASC 820. The use of a single LE provider is not expected to result in assets being valued at a price greater than what could be obtained in an orderly
transaction between market participants at the measurement date. Only with accurate life expectancy information can the Manager determine whether the proposed transaction price is beneficial (i.e., potentially profitable) to the Fund.

IV.
 SEC Chief Counsel Office and Chief Accounting Office Comments Received April 8, 2025
– N-2 Comments

10.
 Please revise the “Investment Strategy” section for clarity. For example, the revised disclosure
states that the Fund will invest in structured products related to Mortality Contracts and Longevity Assets, but Mortality Contracts are defined as a subset of Longevity Assets.

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 April 11, 2025

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 5

 Please see the cover page of the Registration Statement where the reference to bonds has been
removed. The Fund anticipates investing in structured finance products only where such structured finance products primarily hold fixed Mortality Contracts and matched Annuity Contracts.

11.
 Please revise the first sentence in the disclosure under Investment Strategy, as the language seems a bit
confusing. Appears there was an errant reference to “certain structured finance projects which invest primarily in Longevity Assets and bonds.”

Please see the cover page and page A-3 of the Revised Registration Statement that has been revised as
follows:

 The Fund has adopted a fundamental policy that, under normal market conditions, will require the Fund to invest at least 25% of
its total assets in Longevity Assets (including structured products collateralized by Longevity Assets), and other investments with similar economic characteristics.

The Fund confirms that it will not be investing in structured finance products that invest primarily in bonds. The Fund intends to invest in
structured finance products where the pools of assets held by such structured finance products are composed primarily of Mortality Contracts and matched Annuity Contracts.

12.
 Please disclose the specific kinds of bonds the Fund intends to invest in and provide related risk
disclosure.

 The Fund confirms that it will not be investing primarily in bonds. The Fund may invest in US Treasury
bonds for liquidity and potentially defensive purposes.

13.
 Please also consider further disclosing how the Fund is allocating its investments.

 The Fund believes that its current disclosure that it will investment primarily in “an actively managed, large
and diversified portfolio of “Longevity Assets,” consisting primarily of “Mortality Contracts” and to a lesser extent, “Annuity Contracts,” and certain structured finance products that hold Longevity Assets as their
principal investments” accurately reflects the intended investment mandate of the Fund.

 Consistent with this disclosure, the
Fund’s goal is to invest up to 80% of its assets into Longevity Assets, with an additional goal to ensure that at least 40% of its assets qualify as investment securities.

14.
 Disclose that “Subsidiary” includes entities that engage in investment activities in securities or
other assets that are primarily controlled by the Fund. (Tell the registrant what “primarily controlled” means per description above.) See alternative disclosure comment in item 3 below for funds that define “subsidiary” as
including only wholly-owned subsidiaries and/or majority-owned subsidiaries.

 Please see the cover page and pages A-27 and A-28 of the Revised Registration Statement that has been updated to disclose that Subsidiaries are “wholly-owned by the Fund.”

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15.
 Disclose that the fund complies with the provisions of the Investment Company Act governing investment
policies (Section 8) on an aggregate basis with the Subsidiary.

 Please see the cover page of the Revised
Registration Statement under “Wholly-Owned Subsidiaries” where the Fund discloses that the Fund and any Subsidiaries will be viewed on a consolidated basis with respect to Section 8 of the Investment Company Act.

16.
 Disclose that the fund complies with the provisions of the Investment Company Act governing capital
structure and leverage (Section 18) on an aggregate basis with the Subsidiary so that the fund treats the Subsidiary’s debt as its own for purposes of Section 18.

Please see the cover page of the Revised Registration Statement under “Wholly-Owned Subsidiaries” where the Fund discloses that the
Fund and any Subsidiaries will be viewed on a consolidated basis